Data Protection at NCGE/Euroguidance Ireland

The National Centre for Guidance in Education is an agency of the Department of Education and Skills, with responsibility to support and develop guidance practice in all areas of education and to inform the policy of the Department in the field of guidance. NCGE also host the Euroguidance Centre Ireland. NCGE / Euroguidance Ireland gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

The registered office of NCGE / Euroguidance Ireland is:

Avoca House,

189 - 193 Parnell Street,

Dublin 1

D01 P6X2,

Ireland.

Our designated Data Compliance Officer can be contacted at:

mydata@ncge.ie

GDPR is the General Data Protection Regulation. It comes into effect from 25 May 2018. It sets out a series of new EU laws concerning how data is processed and used. The objective of the regulation is to strengthen and standardise data protection laws for all EU citizens. These regulations will apply to any organisation that controls and/or processes data on behalf of an individual or group of individuals. Those responsible for adhering to these regulations include employees of the organisation, including contractors, consultants, agents and third parties who have access to data either directly or indirectly.

NCGE/Euroguidance Ireland has been working to strengthen your rights in line with this regulation, in simple terms this means you have - 

• The right to be informed.
• The right of access.
• The right to rectification.
• The right to erasure.
• The right to restrict processing.
• The right to data portability.
• The right to object.
• Rights in relation to automated decision making and profiling

NCGE / Euroguidance Ireland processes your personal information to meet our legal, statutory and contractual obligations and to provide you with general (relevant) information, resources and continuing professional development  We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

The personal data that we may collect from you is: -

• Name
• Business Email
• Personal Email
• Place of work and Employer
• Role / Occupation
• Home Telephone Number
• Mobile Telephone Number
• Home Address
• Work Address
• Relevant (only) professional qualifications

We collect information in the below ways: -

• Online forms
• Paper forms
• Through E-mail
• Over the telephone

NCGE / Euroguidance Ireland takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law.

We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us communicating with you - you are free to withdraw this consent at any time. 

The purposes and reasons for processing your personal data are detailed below: -

• Ongoing Communications: We will occasionally send you information where we have assessed that it is beneficial to you as a member of the guidance community or as a student/learner. Such information will be non-intrusive and is processed on the grounds of legitimate interests.
• Online learning and meetings: We collect personal information that you give to us as part of the registration process for the NCGE/Euroguidance Ireland learning platform (VLE) and for the purpose of enabling access to the 'Adobe Connect' online meeting space . We may  collect information as you work your way through each learning module. This may include the questions you complete and your results.  We may use your personal information for the purposes of administering and improving the online learning platform, improving our services or communicating with you as users / learners.

You have the right to access any personal information that NCGE/Euroguidance Ireland processes about you and to request information about:

What personal data we hold about you

• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any individual communications from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

NCGE/Euroguidance Ireland takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: -

• SSL
• Encryptions
• Pseudonymisation
• Restricted access
• IT authentication
• Firewalls
• Anti-virus/malware

NCGE/Euroguidance Ireland has consistently maintained a ‘double opt-in’ (also known as granular) approach for subscribers to 'ongoing communications'. This means that any person who subscribes must confirm their request twice. The first time is being when a user submits an email address to the web based form. After the initial request is received by the email list software a special confirmation email is sent to the address the person inputted into the form. This is the second opt-in. The email contains a link which the recipient must click to confirm their subscription request. Once they have done this they have “double opted-in”.

You have the opportunity at any stage to withdraw your consent using the unsubscribe link at the bottom of any e-mail you receive from us, or by e-mailing your request, giving the nature of the communication you would no longer like to receive to mydata@ncge.ie 

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. NCGE/Euroguidance Ireland uses third parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

• Mailchimp (email marketing)
• Survey Monkey (survey gathering and research)
• Google (analytics)
• Adobe (online meetings & webinars)
• Enovation Ltd (website development and LMS* provision)

*Learning Management Support

A subject access request (SAR) is a request for access to the personal information that NCGE / Euroguidance Ireland holds about you, which we are required to provide under the GDPR (unless an exemption applies).

The information that we provide is:

•           the purposes of the processing

•           the categories of personal data concerned

•           the recipient(s) or categories of recipient(s) to whom the personal data have been or will be disclosed

•           If the data has been transferred to a third country or international organisation(s) (and if applicable, the appropriate safeguards used)

•           the envisaged period for which the personal data will be stored (or the criteria used to determine that period)

•           where the personal data was not collected directly from the individual, any available information as to its source

SUBJECT ACCESS REQUEST FORM

You can make this request by post using the details provided on the form above or you can submit your access request electronically, details are again provided on the form. 

Where a request is received by electronic means, we will provide the requested information in a commonly used electronic form (unless otherwise requested by you).

We will provide the information within 30 days free of charge

NCGE/Euroguidance Ireland only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.

Where you have consented to us using your details for ongoing communications, we will keep such data until you notify us otherwise and/or withdraw your consent.

Where you have consented to us using your details for online learning and meetings, we will keep such data until you notify us otherwise and/or withdraw your consent for that purpose.

The right to be forgotten:

You may ask us to delete your personal information or we may delete your personal information under the following conditions:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw your consent where there is no other legal ground for the processing;
• you withdraw your consent for ‘ongoing communications’ / ‘online learning and meeting purposes’;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation.

Where possible NCGE/Euroguidance Ireland can share a digital copy of your information directly with you or another organisation. We will provide this information in a structured, commonly used and machine-readable format. Note, we can only share this information where it has been processed automatically (hard copy documents are excluded for portability) and was processed under your consent.

If you require us to do this on your behalf please contact us at mydata@ncge.ie 

You are not obligated to provide your personal information to NCGE/Euroguidance Ireland, however, where this information is required we will not be able to offer some/all our services without it.

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as previously visited pages or logging in options. Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly.

The cookies we use on our website are either ‘Essential’ or ‘Performance’ Cookies: Essential cookies enable you to move around the website and access its feature, such as accessing secure areas of a website or displaying personalised content. Performance cookies allow us to count the number of visitors to our website and to see how visitors move around the website when they are using it. All counting and tracking is completely anonymous and movements and activity are not traced back to an individual user. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We also use Google Analytics to collect information about your online activity on the website, such as the web pages you visit, the links you click, and the searches you conduct on the website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the website from and the pages they visited.

For more information about the information gathered using Google Analytics please visit https://support.google.com/analytics/answer/6004245?hl=en.

Cookies cannot look into your computer and obtain information about you or your family or read any material kept on your hard drive and, unless you have logged onto an authenticated page, cookies cannot be used to identify who you are. Cookies cannot be used by anyone else who has access to the computer to find out anything about you, other than the fact that someone using the computer has visited a certain website. Cookies do not in any way compromise the security of your computer. Cookies will not be used to contact you for marketing purposes. Cookies may be used to record details of pages that have been visited on this website, however these are anonymous statistics and we do not track you as an individual user. This is to provide us with generic usage statistics to allow the company to improve this website and to provide you with information that may interest you.

How can you control the cookies we use?

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. You can usually activate these settings by clicking on the ‘Help’ menu in your browser. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit

www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit

http://tools.google.com/dlpage/gaoptout

Unless you have adjusted your browser setting so that it will refuse cookies, you will receive cookies as soon you visit our website. The cookies that will be issued will be applied in accordance with the terms of this cookies policy.

Click here to opt-out of Google Analytics for this site only 

• Data storage – how is the school storing data (especially sensitive data) – is this data secure, who has access to the data and why.  How long will the school store the data?
• Consent – has consent been sought from students and parents re the gathering, processing and storage of data – the student and/or parent should be aware of why the data is being gathered, how it will be processed, for what purpose and who will have access to the data and why.
• Data processing – the school needs to ensure that the data it holds is accurate and up-to-date.

http://gdprandyou.ie/

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR).

NCGE / Euroguidance Ireland utilises the US based platforms

• ‘Mailchimp’
• ‘Survey Monkey’.
• ‘Adobe Connect’

Therefore, when you use our sign up form, respond to certain questionnaires or participate in online meetings and webinars  the personal information you submit may be stored on servers which are hosted in the USA.  Mailchimp, Survey Monkey and Adobe have taken steps to ensure that they provide the necessary level of protection for your information and abide by strict agreements and measures set out in order to protect your data and comply with the relevant data protection laws. They all participate in and have certified compliance with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.

NCGE / Euroguidance Ireland have 'Data Processor Agreements' in place with respect the processing of your data with each of the entities listed above.

NCGE/Euroguidance Ireland only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws.

If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, please contact us directly, you also have the right to lodge a complaint with the supervisory authority.

NCGE / Euroguidance Ireland contact information

NCGE/Euroguidance Ireland

Data Compliance Officer

Avoca House,

189 - 193 Parnell Street,

Dublin 1

D01 P6X2,

Ireland.

Ph: 01 8690715 / E-Mail: mydata@ncge.ie

Supervisory Authority:

Office of the Information Commissioner

6 Earlsfort Terrace

Dublin 2

D02 W773

Telephone                   +353 1 639 5689

E-mail                          info@oic.ie